Is the Minister required to prove that there is a debt in order to be successful in a personal injury claim?

Citing a previous Tax Court of Canada decision (Mignardi v. The Queen, 2013 TCC 67, [2013] TCJ No. 66), the judge reiterated that the burden of proof is not to be shifted lightly, and that the Minister is not be required to prove the existence of a tax debt, except in the event that the Minister has particular knowledge of the facts pertaining to this debt. In that case, the judge was of the opinion that there was no need to shift the burden of proof since the tax debtor was the appellant’s husband and the appellant was able to obtain the information needed to challenge the underlying assessment.